Reflecting on the new Constitution of India, Kengal Hanumanthaiah – a member of the Constituent Assembly – remarked in 1949, “We wanted the music of a veena or sitar, but here we have the music of an English band.” His disappointment in the heritage of the constitution was well founded. Half of its provisions were lifted directly from the UK parliament’s 1935 Government of India Act, and the institutional framework it created was recognisably that of Westminster.
The end of the British Empire marked the final years of a long period when, in the words of President Woodrow Wilson, the Westminster model had been “the world’s fashion”. This fashion reached its height with the creation of Westminster-style democracies in Australia, Canada, New Zealand and large parts of Africa, the Caribbean and Asia.
The Westminster model is a shorthand description of the British system of government. There is no set definition of the model’s main elements – different accounts pick out different features, if they define it at all. However, various factors are important. The first set of features follow from the ‘First Past the Post’ electoral system, which tends to produce majority governments, even when a party has a minority of the popular vote. (In 2024, for example, the Labour Party got 34% of the popular vote, but 63% of the seats in the House of Commons.) In the UK, this electoral system has historically supported the development of a two-party system. This ‘majoritarian’ system is often contrasted to ‘consociational systems’ found elsewhere in Europe, where proportional representation, greater power-sharing and coalition governments are the norm.
A second feature of the Westminster model involves the concentration of executive (or ‘decision-making’) power. The prime minister and cabinet are drawn from parliament. There is no separation of powers between the legislature and executive, as there is in many states. This has led to accusations of ‘executive dominance’ or – in Lord Hailsham’s phrase – ‘elective dictatorship’. A government with a majority, supported by strong party discipline, has very few checks to its power. Theoretically and historically, there is limited constitutional protection for minorities in the Westminster model.
Various other features are often listed, including parliamentary sovereignty; ‘weak bicameralism’ with a lower house dominating an upper house; a neutral civil service; or a ceremonial Head of State in the monarchy. (Some of these features have come under threat in recent decades and some academics now argue that it’s time to ‘retire’ the Westminster model as a useful description.) The advantage of the model, as advocates since Walter Bagehot have claimed, is its ability to combine accountability and effective governance.
Eastminster deviations and decolonisation
The spread of Empire exported the British parliamentary model around the world. It is most frequently identified with countries where it was ‘transplanted’ by settlers of British ancestry, such as Australia, Canada and New Zealand. However, the populations to which the system was transplanted are dwarfed by those for which the Westminster model was ‘implanted’ – in particular throughout Asia. Harshan Kumarasingham coined the term ‘Eastminster’ to describe those states that had clear institutional and political resemblances to the Westminster model as part of their colonial legacy, but with significant cultural and constitutional deviations.
Kumarasingham notes several important deviations between the Westminster model and the ‘implanted’ Eastminster political systems. First, there were differences between ‘settler states’ and the Eastminster states. Unlike countries such as Canada and Australia, states in Asia did not contain substantial ‘settler’ populations that dominated the new governments. The model was instead overlaid onto a network of local elites, cultures, governance traditions and social, ethnic and religious divisions. This made implanting the Westminster model onto these existing schisms problematic.
Second, deviations developed over the role of the head of state. The Westminster model in the UK, Canada, New Zealand or Australia largely relegated the monarch (or their representative) to a ceremonial role. In contrast, Eastminster heads of state – although modelled on the British monarchy – frequently engaged in political activities. In Pakistan, for example, Governor-General Ghulam Mohammad tended to view cabinet decisions as advice, which he was free to reject. This level of intervention was almost unheard of under the Westminster model.
Third, deviations occured because of the strong executive power found in the Westminster model, which resulted in ‘selective’ (rather than ‘elective’) dictatorships in Asia. Eastminster states did not often exhibit the conditions to make a two-party democratic system functional. It was more common that one party dominated politics, such as the Indian National Congress; or that elites limited the role of the political opposition, such as Malaysia’s Alliance.
Fourth, deviations emerged as a result of the tensions between majoritarian rule and minority rights. Eastminster models provided few protections for minorities from the governing majority. The ‘First Past the Post’ electoral system tended to create majority governments whose leaders came from the dominant group in their society. There were few protections built in. In Sri Lanka (as it is now), for example, the linguistic rights of a significant minority were removed in parliament on a show of hands, without breaking the constitution.
Finally, divergences developed due to legacies left over from colonial systems of government and the use of unwritten conventions. In particular, colonial emergency provisions were often transferred to the new constitution. In Nepal, conventions around emergency power were left with the Nepali King, not parliament or the executive. In Sri Lanka, the monarch’s representative, Sir Oliver Goonetilleke, used emergency laws during the 1958 riots to direct the cabinet, police and military, whilst seeking to dispense with the convention that the governor-general’s title of commander-in-chief was merely ceremonial. All these divergences show the dangers of implanting one system into another.
The Eastminster model reconsidered
For many critics a focus on ‘models’, whether Westminster or Eastminster, is misleading. They argue that attempting to pull all the features of the British political system into one model will result in ambiguity at best. The term ‘Westminster model’ has been used to refer to a wide variety of different features, which change over time. Applying this to the Eastminster models of Asia, critics would note the diversity of features of the model initially used in different countries. The constitutional experiences of India, Pakistan, Sri Lanka and Malaysia have been utterly different. To lump them all together does that difference a disservice.
Other critics have argued that a focus on the inheritance of Empire, which is core to the Eastminster model, neglects the way that political and constitutional arrangements changed in different states in the years after independence. These possibilities range from a broad adherence to the Westminster model (in India perhaps); to mixing Westminster with other traditions (such as in Australian federalism); or converting it to something new (Pakistan’s military authoritarianism or Singapore’s one-party regime, for example). The focus on Westminster as an influence hides the way in which other influences played different roles in the political and constitutional histories of various states.
These criticisms miss two important lessons of the Eastminster model, which Kumarasingham’s work brings out, though. The first is a reminder, especially for those studying British politics, of the huge reach that the institutions in question have had. Courses on British politics, at least in the UK, are still often taught as if the Westminster model never left Britain and had no influence beyond these shores. Yet the Westminster model was a vital part of the postcolonial histories of India, Pakistan, Sri Lanka, Malaysia, Nepal and many other parts of the globe. As Kumarasingham notes, in 1950 the population of the UK, Canada, Australia, South Africa and New Zealand was just a fifth of the population of the Asian states of India, Pakistan, Nepal, Sri Lanka and Malaysia. The proportion of the world who lived under systems implanted from the Westminster model alone is historically significant.
The second lesson concerns the risks and repercussions of transplanting democratic systems. The Westminster model – with its concentration of executive power, majoritarian rule and reliance on convention – developed against a distinct political and cultural backdrop. Transplanted to very different social and political circumstances, its limitations were far more evident, often failing to protect minorities, ensure peace, or provide lasting democratic stability. In the years after the Second World War, the British academic, Sir Ivor Jennings, played a key role in the new constitutional arrangements emerging across the post-colonial world. He provided advice to numerous countries in Africa and Asia. One reviewer of his book on self-government noted his belief that constitutions cannot be ‘taken off the peg, ready-made: they must be made to measure’. Yet the political and constitutional arrangements that Jennings favoured were invariably from the Westminster system. The suits must be ‘made to measure’ but they were recognisably cut in London, from materials deemed appropriate to those conditions. The influence of the Westminster model in Asia, ill-fitting as it sometimes was, makes it worth reflecting on today.
Simon Griffiths.
Simon is a Reader in British Politics at Goldsmiths, University of London where he was, until recently, Head of Department. His work is focused on the relationships between ideologies, party politics and public policy.
The Constitution Society is committed to the promotion of informed debate and is politically impartial. Any views expressed in this article are the personal views of the author and not those of The Constitution Society.